ML19165A006

(SSES) License Amendment Request for Proposed Changes to Emergency Response Organization Staffing Augmentation. Pre-Submittal Call Meeting June 18, 2019

ML19165A006
Person / Time
Site:	Susquehanna
Issue date:	06/18/2019
From:	Cimorelli K Talen Energy
To:	Jennifer Tobin Plant Licensing Branch 1
Tobin J
References
Download: ML19165A006 (12)

Text

Susquehanna Steam Electric Station (SSES)

License Amendment Request for Proposed Changes to Emergency Response Organization Staffing and Augmentation Pre-Submittal Call Meeting June 18, 2019 1

Purpose Emergency Plan Licensing Basis Proposed Changes Precedent Agenda Regulatory Requirements and Guidance Schedule Conclusion Questions 2

To outline proposed Susquehanna Steam Electric Station (SSES) Emergency Plan changes and the considerations used in development of the License Amendment Request (LAR),

including:

Purpose Regulatory Requirements Regulatory Guidance Current NRC Staff Positions Recent NRC Approvals of Industry Submittals 3

SSES Emergency Plan, approved by the NRC via Safety Evaluation Report (SER), dated March 24, 2003 changed from 30 and 60 minute ERO response to 60 and 90 minute response.

The current SSES Emergency Plan maintains 60 Licensing Basis and 90 minute response.

The LAR includes an analysis of NUREG-0654 Table B-1 functions between the last approved and current revision.

Proposed Emergency Plan changes will maintain 60 and 90 minute response.

4

• Remove references to performance of maintenance tasks on-shift.

• Reduce the number of augmented RP Proposed Technicians from 8 to 6.

Changes

• Remove augmented Chemistry position.

• Revise the definition of facility activation to describe TSC and OSC in terms of staffed and ready to assume command and control functions at an Alert or higher classification.

5

• Classification, Notification, Dose Assessment and PAR Determination remain at TSC.

• Extend response times for some TSC and OSC positions to 90 minutes.

Proposed

• Require staffing of the EOF and JIC at an Alert or Changes higher classification.

(contd)

• Reduce the size of the augmented ERO to leverage efficiencies gained by consolidating command and control functions in the TSC.

• Administrative positions controlled via EPIPs.

6

Safety Evaluations issued for the following:

Point Beach (ML16118A154)

Duane Arnold (ML17220A026)

Monticello (ML17349A91)

Precedent Prairie Island (ML17362A202)

South Texas Project (ML18158A212)

Sequoyah (ML18159A461) 7

10 CFR 50.47(b)

Applicable 10 CFR 50.54(q)

Regulatory 10 CFR 50, Appendix E Requirements 10 CFR 50.90 8

Regulatory Guide 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, Revision 1 Nuclear Regulatory Commission (NRC) Interim Staff Guidance NSIR/DPR-ISG-01, Emergency Planning for Nuclear Power Plants Nuclear Energy Institute (NEI) 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Applicable Capabilities Guidance NUREG-0654/FEMA-REP-1, Criteria for Preparation and Documents Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1 Regulatory Information Summary (RIS) 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation NRC Letter to NEI, Alternative Guidance for Licensee Emergency Response Organizations 9

Submit LAR by September 30, 2019 Request approval within one year of submittal acceptance.

Schedule Propose a 120-day implementation period 10

Based on the technical, functional, and staffing analyses performed, Susquehanna has concluded that the proposed changes:

Maintain support for the required Emergency Plan functions Conclusion Continue to ensure the protection of public health and safety Comply with applicable regulatory requirements 11

Questions Questions?

12